Lemke v. Commonwealth’s Empirical Analysis
1978
Citation profile
15 state decisions
How this case has been cited
Cited by 15 later decisions — most recently May 2007
15 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Argersinger v. Hamlin · Ungar v. Sarafite · Lee v. United States · United States v. Terry · Watkins v. Commonwealth
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Trial courts are fully justified in taking stern measures to eliminate the frustrations of unnecessary or intentional delays caused by defendants in criminal appeals from the General District Courts. Such defendants must not be permitted to trifle with the courts or impede the administration of justice.... Nor does the evidence establish that Lemke acted in bad faith in appearing for trial without an attorney and moving for a continuance. Although the representations made to the court by the attorney whom she sought to employ were not entirely consistent with Lemke’s own statements, they showed that she had made an effort during the week before trial to obtain the services of counsel. It thus appears that she wished to be represented by an attorney.”
1 later decision quote this exact passage · from the majority“[W]henever a person charged with a criminal offense the penalty for which may be death or confinement in the state correctional facility or jail . . . appears before any court without being represented by counsel, the court shall inform him of his right to counsel. The accused shall be allowed a reasonable opportunity to employ counsel, or, if appropriate, the statement of indigence provided for in § 19.2-159 may be executed.”
1 later decision quote this exact passage · from the majority“record does not show that the trial judge followed the procedures mandated by Code §§ 19.2-157, et seq., to determine whether the defendant wished to waive [the] right to counsel.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.